Written Evidence submitted by The National Sheep Association (maab0027)
1. Does the UK have sufficient resources and capacity to certify, record and inspect animal movements across its borders?
The agreement reached between the UK and EU has resulted in a serious lack of equity between our nations in relation to moving animals across our borders. We believe this has been exacerbated by the UK Governments decision to move away from import and export controls that are equivalent in favour of an easing of import access into the UK ‘to keep our businesses working’. The result is that we are bringing live animals into the UK (prior to BCPs with the infrastructure to take live animals) but we are unable to export live animals from the UK to the EU. British sheep farming exports a minimum of 8500 high value breeding sheep annually over the short straights alone with more crossing the Irish border and some from other English ports. The number of sheep imported to the UK is estimated to be in the low hundreds. The number of farmers affected may be low but the impact on them will be high. The problem is caused by there being currently no BCPs on the northern EU coast with live animal facilities.
So in direct answer to this question, the UK does not have the facilities to import live animals but has implemented a system of inspections at the point of destination as an interim measure. Resources to certify and inspect imported animals are stretched due to a general shortage of vets, in part due to high demand for dealing with export health certificates. The Food Industry raised concerns in a letter (dated 4th December 2020) to George Eustice calling for: “more government-employed official veterinarians to be made available for this work; simplified guidance about how official veterinarians can rely on existing controls; and an increased role of certification support officers.” There continue to be concerns raised over the availability of veterinary resources. To add further burden, much of our existing vet capacity comes from EU labour sources which have been impacted by new entry requirements for non-UK workers. We are not able to export animals due to no facilities and systems being available on the EU coastal ports.
Import movements are further impacted due to drivers and vehicles needing approval and certification in both the EU and the UK, and few having completed this process.Some of the initial disruption may be due to teething problems and user error, however, there are still major concerns for the UK sheep sector around animal movements across its borders.
On the subject of exporting live animals to the EU, everything is currently on hold due to there being no facilities at any of the EU sea ports to take live animals from a non-EU state. For breeding animals, we are expecting solutions in time with a couple of options potentially being developed. As far as we are aware, the P&O ferries that use to ship breeding sheep from Dover to Calais are closed to live animals, and except for flying animals out, NSA is not aware of any other options. The same applies to any lambs moving across the channel for slaughter or further finishing, although decisions relating to this will be caught up in the Governments current consultation on banning live exports for anything other than breeding stock. Note that breeding stock will also have to be Scrapie free and stated free from the main iceberg diseases by the farm’s vet, adding further problems once facilities are in place. To add insult to injury the 6 months grace allowed to the EU means that live animals can make inward journeys without the need for the controls any exported animals would need.
2. How effectively will the UK be able to conduct animal disease surveillance and respond to outbreaks?
Disease control and the avoidance of importing disease, particularly zoonotic diseases or pathogens that risk crossing species, is essential if we are to avoid repeats of the current Covid pandemic. Covid-19 has exposed failures to respond effectively to the emergence of a highly contagious and lethal microbial threat. Over the past 20 years a number of high impact pathogens have emerged or re-emerged, such as three new coronaviruses—namely, severe acute respiratory syndrome (SARS) in 2003; Middle East respiratory syndrome (MERS) in 2012; and the current covid-19 pandemic (SARS-CoV-2). We have also seen several highly pathogenic influenza A viruses (eg, H5N1 in 2003; H7N9 in 2013; and the H1N1 pandemic in 2009), the Zika virus in 2016, and the continuing rise and spread of Ebola in West and Central Africa since 2013. All these pathogens have jumped from transmission among non-human animals to transmission among humans. During this century, the frequency of epidemics and pandemics might continue to increase, driven mainly by demographic trends, such as urbanisation, environmental degradation, climate change, persistent social and economic inequalities, and globalised trade and travel. To avoid this border controls, surveillance, and high levels of biosecurity are essential.
In addition to strengthening existing health systems, key to these efforts is building a surveillance system that spans wildlife, livestock, and human populations. Such a system would use known geographical “hot spots” for early detection of any viral transfer into human and livestock populations, and pre-emptively disrupt further transmission of the virus locally. Pre-emptive action would contribute to an enhanced ability to forecast future threats and enable early intervention.
The current disruption at points of entry & exit, together with the stretched veterinary resources add to the concerns over how secure our borders might be and their ability to deal with any suspected disease. The NSA is concerned that with the absence of proper live animal BCPs short term point of destination checks are being done. This is leading to further transport distances prior to testing than are ideal, and the risk of disease spread at the point of destination where other livestock may be present.
We are aware of a number of ports with an interest in building live animal facilities but there is inadequate confidence to invest particularly when the government is consulting on journey times and welfare in transport, with the express intention of banning live exports for slaughter and further finishing. This situation is adding confusion and undemining confidence meaning few are willing to invest. There is also inadequate Govt support being made available and live animal facilities are being pushed away from port curtilages due to planning controls and high land values in close proximity to ports. Any additional distance between the port of entry and the live animal facility will only increase disease entry to Britain.
3. What impact will the new UK-EU agreement have on moving animals across the Irish border and between GB and the EU/Northern Ireland?
We don’t believe there will be an impact on sheep travelling between Northern and Soutern Ireland, although it is highly likely that if it remains impossible to move animals across the short straights then there is a risk that animals will end up travelling further, through NI, into Southern Ireland, and to southern EU from the Irish ports. This is more likely with cattle due to the Scrapie controls that now exist between GB and NI but depending on what happens in the future this scenario is a risk with sheep as well. The situation faced by sheep breeders in Northern Ireland (NI) and those on the UK mainland who are involved in mainland/NI breeding stock trade is now completely disrupted, and with no effective warning or understanding that this was to happen. . It has always been NSA’s understanding, there would be ‘free and frictionless’ trade between GB and NI and this was repeatedly committed to by the UK Govt. However the border between the UK and the EU is effectively now between GB and NI meaning additional health and phytosanitary controls for goods moving between our nations, ultimately casting NI adrift. More recently (March) a decision has been made to extend the transition period to fuller movement controls but this appears to have had no effect on the implementation of live animal controls.
The major challenge is NI having to adopt EU SPS (Sanitary and Phytosanitary) controls meaning that sheep going to NI from GB will need to be Scrapie free as well as MV free.
Another challenge posed by EU sanctions mean pedigree stock travelling from NI to GB for sales and shows will also fall foul to the EU legislation due to in excess of a six-month residency requirement for any stock wishing to return to NI. Unfortunately, DAERA appear to have their hands tied and live animal movements rests with further negotiations between UK government and the EU for a potential derogation, exemption, or physical change to EU legislation.
Each year between 9000 and 18,000 sheep of high value are moved between NI and mainland Great Britain, some being multi-thousand pounds rams of high genetic value. On an industry scale this may be considered small but for individuals affected the restrictions on movements to be imposed are creating catastrophic consequences for many of our pedigree breeders and those trading in commercial breeding animals on both sides of the water.
There is no consideration of the movements of live breeding animals and the fact that many livestock farmers integrate their businesses and marketing within GB trade. The need for breeding animals to be scrapie monitored was not expected yet it takes 3 years to get through this scheme, hence there will be a major disruption in this trade. Similarly, NI farmers bringing breeding animals to GB society sales now appear to face a potential 6-month lockdown period before they could return if unsold.
New tagging requirements are also disrupting trade between GB and NI, as well as risking a break in traceability. To remove and replace UK tags with NI ones with completely different numbers seems unnecessary and is likely to lead to a loss of traceability. A high proportion of stock moved between GB and NI are registered pedigree animals and several sheep breed societies have reported that their databases will not have the ability to change registration numbers. Changing databases to enable this will be costly and could reduce values for animals involved in this trade.
4. How should the Government balance animal health and welfare alongside economic interests?
The two areas of interest HAVE to work together. We will not see good health and welfare if the economics of livestock farming are not favourable, and livestock farming is unlikely to be economically viable if the health and welfare of animals is not good. Improving the health and welfare of Britains sheep farming offers the best opportunity to improve the industrys productivity, without any need to change the structure and diversity of the industry. While there is more R&D to be done on some sheep diseases (particularly the ‘iceberg diseases such as MV, OPA, Johnes, and CLA) many loss causing diseases, such as contagious abortion, parasitic gastro enteritis, and clostridial disease, have answers and solutions and the challenge here is to get higher adoption of good practice.
For sheep farming our strong opinion is that the first priority in improving productivity (the economic performance of the sheep flock) is to invest in health improvements – if we we improve the health status of our flocks then we will go a long way to improving the welfare of our sheep. We are also of the opinion that health and welfare will be best served by optimising rather than maximising production (not productivity). We should not be tempted to make genetic changes in pursuit of meat yield (for example) if it threatens the welfare of our flocks. Of course there are more ‘systems based’ welfare improvements that can be made, loading and transport approaches, non stun slaughter, handling of sheep prior to shearing, avoiding castration where possible, and the licensing of anaesthetics and analgesics for use in sheep, but it is difficult to demonstrate economic gain from these improvements and investments.
Because of the fact that not all welfare gains lead to economic improvements it is likely that progress will be best made by public rewards for animal welfare enhancements. And because more confidence needs to be built around the benefits to economic performance of an investment in health related actions it is also likely that gains will be best made by Govt incentives to aid and support investment. Both these approaches could be aided significantly by the proposed Defra Pathway programme. However it is also right to use the market as far as possible to support high health and welfare livestock farming approaches. This can be done in two main ways – to create demand and premiums for high health and welfare livestock products; and to protect our health and welfare standards by not allowing imports not produced to our standards to enter and undermine our market. High health and welfare standard markets exist domestically and in many export markets.
In relation to health, welfare, and economic interests dependant on movement of animals across borders then the answer is likely to lie in setting regulations and standards and ensuring enforcement – even when animals are moved across borders. This has been one of the biggest problems with live exports – ensuring enforcement in other countries and it could be dealt with by way of an export assurance scheme where compliance could be demonstrated. However, more research needs to be done, and understanding gained to assess stress and welfare in animal transport.
Live animal exports:
5. What impact will ending live animal exports for slaughter and fattening have on UK farmers, processors and other businesses?
A prohibition on live exports from the UK would impact financially on our members and on the sheep industry. The level of impact would vary annually depending on other factors and there is a risk that in difficult market conditions the loss of live exports would push prices down with a resultant negative impact on the health and welfare of the sheep flock.
The answer to this question is dependant in part on what is meant by ending live animal exports … for UK farmers. The biggest proportion of live sheep exports by far move across the NI /SI border and these animals go both ways for slaughter, and may not travel very far. A far smaller number of sheep (some 25,000 annually) travel across the short straights and these go mainly to finishers and abattoirs in northern Europe. Numerically these 25,000 sheep are not highly significant – but taking a buyer out of the market at times when sheep numbers are high can have a negative impact on prices. There are a small number of specialist businesses that operate in the area of live exports and a ban on these movements is likely to be terminal for these businesses. Domestic transporters and breeders of breeding stock for export may be impacted by a reduction in the number of export journeys and a general rise in costs..
With the exception of processors in NI, mainland UK processors are unlikely to be affected by any ban, but it is right to remind that for some farmers in the South east of England, sending sheep across the short straights can result in a longer journey than internal routes to, for instance West Wales or the north of England. The South and South east of England is not well served in relation to slaughtering capacity.
6. Does the UK have sufficient capacity to slaughter and process animals that are currently exported? If not, what could be improved?
As a general principle NSA believes it is preferable for sheep to be slaughtered as close to home as possible, however in terms of welfare this will depend on transport conditions. Research shows that most stress in transport is caused by loading and unloading, and following this poor driver care and attention can have a negative effect on welfare in transport. Therefore a short journey in bad conditions can be worse than a longer journey in good conditions.
The choice of where to
send animals for slaughter must be an economic decision and, with an ever-decreasing number of UK processing facilities, sheep often travel some distance to an abattoir. Restricting this choice removes competition and choice and will reduce economic performance.
The UK mainland does have the slaughtering capacity to cope with the additional number of sheep that would go across the short straights. However it doesn’t have adequate choice to remove yet another buyer from the marketplace. NSA would fully support investment in additional slaughtering facilities to give better regional spread, however we would also expect that regulations or codes may need to be developed to reduce the consolidation that has been seen in the slaughtering sector, and that investment and grant aid would be essential for this to happen. We believe an improved abattoir network may help the labour situation faced by many large plants in getting adequate labour from such a concentrated area. However this conflicts with what is being seen at present with smaller processors struggling to deal with the export and EHC requirements in accessing the EU market. It has been well-documented that small local abattoirs have faced significant problems due to lack of funding and the burden of regulation, causing increasing numbers of them to go out of business in recent years, with a loss of over a third in the past decade alone. Many existing small abattoirs often cannot meet the demand for their services, and many turn customers away, particularly at busy times of year (e.g., April, December). Creating additional pressure through increased demand, further exacerbates the problem.
Further research into the feasibility of the economics, design and use of mobile slaughter facilities to reduce the need to transport animals over long distances is a potential solution. Again, more time is needed for an impact assessment to be conducted to fully evaluate the nation-wide consequences of simply banning live exports for slaughter and fattening purposes. The infrastructure and facilities would need to be in situ before any ban on live exports was imposed.
The Irish situation is different and animal supply and processing is highly integrated across the whole island. There are approximately 350,000 to 400,000 lambs exported for slaughter to the ROI each year. Without those lambs going south competition would be removed from the N.I. market and there would not be the facility in N.I. to almost double the lamb kill capacity.
7. How will Great Britain leaving the EU Pet Travel Scheme affect both legal and illegal movements of animals between GB and the EU/NI
8. Are the current rules and checks on the movement of domestic animals strong enough to prevent illegal activity? If not, what could be improved?
9. What impact will the EU Animal Health Law have on the movement of equines between GB and the EU/NI from April 2021
10. Will the rules and checks on the movement of equines be strong enough to prevent illegal activity? If not, what could be improved?